Larry Fazio's commentary ("Revised RBC Proposal Reflects Lessons Learned," Jan. 22, 2015, CU Times) cites the financial crisis as the catalyst for the NCUA's second risk-based capital proposal, stating that many of the failures would have been prevented in part if this new rule had been in place.

Unfortunately, this is an overgeneralization of a complex issue; capital is only part of the equation. In fact, credit unions experienced many fewer failures than their banking brethren during the crisis, and banks were operating under a risk-based system similar to what NCUA had proposed at that time.

While we are pleased that the NCUA listened to some credit unions' concerns in its second proposal, NAFCU still supports withdrawing this rulemaking and addressing capital reform in Congress. Credit unions need a risk-based system that can account for both higher and lower risk. Neither the current system nor the proposed one achieves this.